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Lysis Financial responds to FCA Short Consultation - Coronavirus & Safeguarding Customers' Funds


FINANCIAL CONDUCT AUTHORITY (FCA)

Coronavirus and safeguarding customers’ funds: proposed guidance for payment firms


  • Our comments are based upon consultancy and operational engagements with payment service providers (PSPs) and insights gained anecdotally from involvement more generally with the industry.

  • Our comments are also shaped by public domain material relating to the administration proceedings relating to Ipagoo LLP (which traded as ipagoo).

  • Remittances to overseas families are a legitimate use of PSPs particularly by the socially excluded.

  • The current environment places this legitimate use of PSPs under stress

  • PSPs should plan for these stresses and be adequately capitalised.

  • The firm’s research and other publications on PSPs are appended to these comments.



1. ‘Do you agree that we should provide additional guidance on safeguarding, managing prudential risk, and wind-down plans? If not, please explain why.’